The YMCA NSW has asked the national inquiry into child sex abuse to reject a proposed finding that it is not a child-safe organisation.

In a written submission to the royal commission into institutional responses to child sexual abuse, the childcare provider also says assertions by counsel advising the commission that senior managers were not fit and proper persons to run a child-safe organisation were "unreasonable".

A report from Gail Furness, the commission's senior counsel, was published in December following a hearing into how YMCA NSW handled recruitment and subsequent allegations against paedophile Jonathan Lord.

Lord is in jail serving six years without parole of a 10-year sentence for sexual offences against 13 children when he was a YMCA childcare worker at Caringbah in southern Sydney.

Furness identified systemic failures in YMCA NSW that enabled Lord to be recruited and work unchecked for two years.

Counsel for the YMCA NSW, Greg Sirtes, argues in a submission published on Monday that Furness's acceptance of the evidence of childcare worker witnesses over the views of Whitley and Hare, while also failing to acknowledge positive steps taken by the institution, meant her recommendation should be rejected.

Throughout the hearing YMCA NSW argued that staff were adequately trained and were manipulated by Lord, or in some cases ignored the child-safety policies.

Furness rejected this in her report and said policy failures plus a failure to do a proper analysis of the events leading to Lord's recruitment, induction, training and supervision were down to management.

She said the conduct of management "did not permit confidence in their capacity to carry out the significant reforms necessary to make YMCA NSW a child-safe organisation".

Sirtes, in his 89-page submission, rejected this as demonstrating "a determination to criticise YMCA NSW whilst at the same time failing to acknowledge any positive steps made or agreed to be taken by the institution in the wake of the Lord incident".

His submission also asked for the rejection of suggestions that YMCA NSW tried to "cover up" the Lord incident by imposing a confidentiality clause on staff, or misled parents at centres where Lord had worked.

The YMCA NSW submission accepts there was mishandling of information after Lord's arrest but put this down to a misunderstanding over a police instruction not to compromise evidence.

The submission says that in response to the royal commission process, the YMCA NSW is implementing a centralised recruitment procedure, plans a third-party root cause analysis into the Lord events and a culture review.

It is also clarifying whistleblower policy and parent awareness of child protection policy.